CITIZENCREDIT C-OPERATIVE BANK LIMITED (MAROL BRANCH),MUMBAI vs. ITO (TDS) WARD 1(1)(4), MUMBAI

ITA 6437/MUM/2025Status: DisposedITAT Mumbai19 January 2026AY 2019-2033 pages
AI SummaryDismissed

What did the Tribunal hold?

The Tribunal held that a co-operative bank is distinct from a general co-operative society and specific provisions of Section 194A, including amendments, mandate TDS on interest payments to non-member co-operative societies. Therefore, the assessee was liable for TDS.

What were the facts?

The assessee, a multi-state co-operative bank, failed to deduct TDS on interest paid to other co-operative societies. The Assessing Officer (AO) held that the assessee was obligated to deduct tax at source under Section 194A of the Income-tax Act, 1961.

What were the issues?

Whether a co-operative bank is exempt from deducting TDS on interest paid to other co-operative societies under Section 194A(3)(v) or if specific provisions mandate such deduction.

Which sections of the Income-tax Act were involved?

Section 194A,Section 201(1),Section 201(1A)

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Before: SHRI NARENDER KUMAR CHOUDHRY & SHRI BIJAYANANDA PRUSETH

For Appellant: Shri Nitesh Joshi a/w Shri Harsh Kothari, Mr. Virabhadra S. Mahajan, Sr. DR
For Respondent: Shri Nitesh Joshi a/w Shri Harsh Kothari, Mr. Virabhadra S. Mahajan, Sr. DR
Hearing: 18/12/2025Pronounced: 19/01/2026

PER BENCH: These 66 appeals filed by the assessee emanate from the orders passed under section 250 of the Income-tax Act, 1961 (in short, ‘Act') by the Addl./JCIT (A) – 10, Delhi, Office of the Commissioner of Income-tax (Appeals), dated 05.09.2025 [in short, ‘CIT(A)'] for the assessment years (AYs) 2016-17, 2017-18, 2018-19 and 2019-20. Since the issues in these appeal are similar except variance in amounts, therefore, with consent of both parties, these appeals were

The order continues below.

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